Recently there have been some clarifications around a couple of sections of the PCI-DSS, in particular one on section 6.6 .
This update has created some comment and articles but none of the ones I've read has focused on the main point, as far as I can see...
Previously there were two options for satisfying Section 6.6

  • A Code Review (either manual or tool assisted) of in-scope web applications, or
  • Placement of an appropriately configured Web Application Firewall to protect the application

Now (unless I'm reading this incorrectly) there's an additional one
Completion of a manual or assisted web application vulnerability review...
The confusing part is that this third option isn't split out but is listed under the "application code review" section.
My feeling is that this'll affect a lot of merchants (and vendors) if they were planning on either spending money on WAFs or Code reviews and will now use a standard web application review (which they may already be undertaking as part of other security work....)
Another interesting point which I don't know the answer to is whether a single review which covered both penetration testing techniques and web application assessment techniques could be used to satisfy 6.6 and 11.3...


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